|
BCS provides services to help companies manage supplier
risks associated with terrorism, money laundering and
identity theft and fraud.
Depending on the industry you work in, federal laws, such as
the PATRIOT Act, The Money Laundering Control Act and
Executive Order 13224, require that companies check each
supplier, contractor and employee that they employ against
certain exclusion databases. These databases include, but
are not limited to the General Services Administration's
(GSA) Excluded Parties List System (EPLS), the Office of
Foreign Asset Control's (OFAC) Specially Designated
Nationals List (SDN), the Bureau of Industry and Security (BIS)
Denied Persons List (DPL) and the Office of Inspector
General's (OIG) List of Excluded Individuals/Entities (LEIE).
BCS maintains a list of your suppliers, contractors and
employees and regularly checks these databases, which are
continuously updated. BCS notifies you electronically with
the identity of those individuals and entities placed in
these exclusion databases. Additional suppliers, contractors
and employees can be added to your database at any time.
What is the purpose of these agencies?
OFAC is the Office of Foreign Asset Control, part of the
U.S. Department of Treasury. OFAC is responsible for
administering and enforcing economic and trade sanctions
against certain nations, entities and individuals. OFAC
maintains a listing of these restricted counter parties in a
document called the "Specially Designated Nationals List" (SDN).
BIS is the Department of Commerce's Bureau of Industry and
Security and maintains two lists; the "Denied Persons List"
and the "Entity List" for Contract Officer consideration.
For those transactions that may involve exports from the
United States or reexports of U.S. origin items, parties
(including U.S. Government officials) are encouraged to
review the Export Administration Regulations (15 C.F.R. 730
et. seq.) maintained by BIS.
GSA, General Services Administration, identifies those
parties excluded from receiving Federal contracts, certain
subcontracts, and certain types of Federal financial and
non-financial assistance and benefits. They maintain the
EPLS, Excluded Parties List System, which keeps its user
community aware of administrative and statutory exclusions
across the entire government, and individuals barred from
entering the United States.
The OIG, Office of the Inspector General, maintains the List
of Excluded Individuals/Entities (LEIE), a database which
provides information to the public, health care providers,
patients and others relating to parties excluded from
participation in the Medicare, Medicaid and all Federal
health care programs. An OIG exclusion has national scope
and is important to many institutional health care providers
because the Congress of the United States established a
Civil Monetary Penalty for institutions that knowingly hire
excluded parties.
It is integral for all businesses that are receiving federal
funding or making payments to include a provision in their
compliance policies to ensure that they are not doing
business with restricted individuals or entities.
Additional information on federal laws:
|
